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Impact of Ligado's Proposal on SATCOM, Aviation and Weather Data Users

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Impact of Ligado's Proposal on SATCOM, Aviation and Weather Data Users Impact of Ligado’s Proposal on SATCOM, Aviation and Weather Data Users SEPTEMBER 2019 1 Overview of the Impact of Ligado’s Proposal FCC rules allow for holders of mobile satellite service (MSS) spectrum to include an “ ancillary ” terrestrial component as part of their service, provided that the service is ancillary and does not cause harmful interference to existing MSS providers After emerging from bankruptcy, in December 2015 Ligado Networks (formerly LightSquared) applied to the FCC to operate a modified ancillary terrestrial network operating in the L‐band (used by GPS, SATCOM providers, and weather/environmental data community) Despite its press push, there remain significant concerns over harmful interference from Ligado’s proposal from multiple parties: • GPS will be heavily impacted by Ligado’s plans, creating safety issues for aviation, and interference to many other types of GPS systems • Ligado’s proposed network will have potentially millions of mobile devices transmitting just 1 MHz away from critical SATCOM services, including cockpit communications • Real‐time weather satellite data from NOAA will face interference if Ligado is approved to operate in 1675‐1680 MHz, degrading data relayed in real time via satellite from stream gauges for flooding, fire sensors for wildfire management, and tide gauges for coastal evacuations in hurricanes 2 L-Band Neighborhood GSO MSS GSO MSS Other Satellite Downlink Uplink Services Including Ligado leased spectrum in 1670-1675 MHz and NOAA in 1675- 1680 MHz Frequency, MHz 3 Impact to GPS Usage • Ligado is planning 10,000+ sites that would interfere with certified aviation GPS when aircraft are operating in close proximity • "The concerns and safety issues of the industry have NOT been addressed, particularly when considering the lack of testing in key areas” - Letter from Eleven Aviation Organizations to FAA Acting Administrator Elwell, June 2018 • GPS interference is a safety of flight issue for low‐level aircraft operators • Threat to medivac, state and local emergency aviation operations • GPS is a key sensor system for the Terrain Awareness and Warning System (TAWS) • Ligado yet to fully explain all necessary control measures • Possible greater impact to other GPS operations • DOT Adjacent Band Compatibility study reported that high‐precision GPS are more vulnerable than certified aviation receivers We believe there are further serious concerns about the impact of Ligado’s proposed operations on special, and scientific users of GPS that should be fully explored, such as: • Unmanned Aerial Vehicles (UAVs) • Weather data and forecast • Space‐based receivers This risk is far too great … for Ligado’s proposal to be approved. While there are many broadband alternatives “ (Ligado would be a very small percentage of this national asset), there is only one GPS. ‐ PNT Advisory Board August 2018 Letter to PNT ExCom 4 ” SatCom: A New Era for Global Connectivity • On January 11, 2019 , a flight‐proven SpaceX Falcon 9 rocket launched from Iridium constellation with Vandenberg Air Force Base and delivered 100% global service area the final 10 Iridium® NEXT satellites to low earth orbit (LEO) • This is the largest satellite constellation replacement ever • 66 cross‐linked, low earth orbit (LEO) satellites • Only fully global voice and data provider; approximately 1,213,000 subscribers • Efficient operations using only 8.725 MHz of spectrum worldwide for uplink and downlink • Messages are routed from satellite to satellite and grounded at teleports Architecture of 6 orbital planes of 11 satellites each at 780 km altitude around the world 5 SatCom: Harmful Interference to Iridium Services • Ligado seeks to operate a modified ancillary terrestrial network operating in the L‐band, including the 10 MHz adjacent to Iridium at 1627.5‐1637.5 MHz • Iridium’s technical analysis (submitted to FCC on Sept. 1, 2016) and aviation‐specific technical analysis (submitted to FCC on Dec. 14, 2016) indicates that this terrestrial operation on that 10 MHz of spectrum would result in significant harmful interference to Iridium’s mobile terminals, including those used for vital SATCOM aviation services • Section 25.255 of the FCC’s rules requires Ligado to resolve any harmful interference from their terrestrial operations; purpose of the rule is clear – maximize flexibility consistent with sound spectrum management while providing absolute interference protection for incumbent MSS providers 6 SatCom: Interference to air traffic control • Interference to SATCOM exists for critical air traffic control and other safety‐of‐ life communications used by the commercial and general aviation industry with the Inmarsat MSS network • In 2016, Ligado acknowledged the potential interference to SATCOM transceivers installed on thousands of in‐service aircraft, and indicated it would collaborate with Inmarsat and others to resolve these issues • Interference from Ligado’s network could likely be avoided through the installation of a new Diplexer/Low Noise Amplifier (DLNA) in each aircraft • The retrofit process would be time‐consuming, costly and require extensive efforts to secure Type Certifications from the FAA • Compensation would be required to cover the significant installation costs for aircraft servicing centers and lost opportunity costs for aircraft owners • Ligado now disclaims any obligation to ensure the retrofit process is funded and completed, and states that the dispute is a disagreement between a vendor and its customers and does not involve Ligado • Ensuring the reliability of aviation safety communications is a fundamental public interest obligation of the Commission 7 Broad Opposition to Ligado Proposal “The [coalition] continues to have serious unresolved concerns with Ligado’s proposed operations … The existing services provided by the GPS, SATCOM, aviation and real‐time environmental satellite data communities, which depend upon interference‐free operations in spectrum adjacent to or co‐channel to spectrum central to Ligado’s plans, are too important to jeopardize, especially for the speculative benefits of Ligado’s constantly evolving proposals, details of which continue to be lacking.” July 18, 2018 ex parte letter Coalition of Aviation, SATCOM and Weather Information Users ● AccuWeather ● American Geophysical Union ● Satelles Inc. ● Aviation Spectrum Resources, Inc. ● International Air Transport Association ● National Air Transportation Association ● Aerospace Industries Association ● American Weather and Climate ● National Hydrologic Warning Council ● DTN (formerly Schneider Electric) Industry Association ● National Weather Association ● Aircraft Owners and Pilots Association ● Iridium Communications, Inc. ● Resilient Navigation & Timing ● General Aviation Manufacturers Association ● American Meteorological Society Foundation ● Airlines for America ● Lockheed Martin ● National Emergency Number ● Gogo Business Aviation ● Microcom Design, Inc. Association ● ALERT Users Group ● Rockwell Collins Inc. ● University of Wisconsin, Space Science ● Helicopter Association International ● Narayan Strategy and Engineering Center 8 Ligado is not 5G • Ligado lacks sufficient contiguous spectrum for 4G, let alone 5G • 5G network designers are contemplating channel widths of 100 megahertz for 5G applications • Even if Ligado is able to cobble together 40 megahertz of spectrum across several different frequency bands, Ligado could at best offer 10 megahertz‐wide channels • The FCC’s 5G FAST Plan does not consider Ligado or L‐band spectrum as part of its 5G plans • Most of the spectrum that Ligado would use for its “5G” network is allocated to satellite services. Ligado has been unable to show that its terrestrial operations will not interfere with satellite operations • Ligado’s spectrum is not part of the 3GPP standards for 5G, or any other recognized standard. Although it claimed that it would become part of the 3GPP standard in 2015, it still hasn’t happened • Ligado’s spectrum is not harmonized regionally for terrestrial use 9 The FCC Should Deny or Disregard Ligado’s Section 7 Request • Section 7 states: “(a) It shall be the policy of the United States to encourage the provision of new technologies and services to the public… (b) The Commission shall determine whether any new technology or service proposed in a petition or application is in the public interest within one year after such petition or application is filed…” • Ligado’s proposed operations do not qualify as “new technologies or services” under Section 7 – The M2Z decision squarely rejects Ligado’s theory – Applications for License and Authority to Operate in the 2155-2175 MHz Band , Order, 22 FCC Rcd 16563 (2007), affirmed M2Z Networks, Inc. v. FCC, 558 F.3d 554 (D.C. Cir. 2009) • Providing 5G service alone cannot satisfy Section 7 • Ligado is not proposing to offer 5G service • Ligado’s proposed system is not otherwise a new technology or new service under Section 7 • Even if Section 7 applied in this instance, the provision’s one‐year shot clock only started ticking on June 25, 2019, the date of Ligado’s Section 7 Request • Even if Ligado were offering a new technology or service, it has not resolved longstanding public interest concerns with its proposed terrestrial network 10 FCC Process • 2001: Mobile Satellite Ventures (MSV), Ligado’s predecessor, applies to provide a terrestrial and spot‐beam satellite service and FCC starts rulemaking to adopt ATC rules • 2003: FCC adopts ATC Order which sets rules for licensing and operation of ATCs
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